Comments on Proposal to Mitigate Name Collision Risks

[Nacho Amadoz <amadoz@xxxxxxxxxx>]

Dear ICANN, 

puntCAT, on its own behalf and representing the interests of the City Council 
of Barcelona regarding the .bcn and .barcelona application, wishes to express 
its comments regarding the Proposal to Mitigate Name Collision Risk. 

We believe that .bcn has been misleadingly labeled as of "uncalculated risk", 
for the reasons already exposed in comments posted by others, such as: 

- the small amount of data involved; 

- the arbitrary threshold selected to differentiate between "low risk" TLDs and 
"uncalculated risk" TLDs; 

- the negligible percentage of requests for non-existing TLDs conflicting with 
strings considered under the new gTLD program, according to the figures present 
in the Interisle report

- the fact that gTLDs such as .bcn have been included in the "uncalculated 
risk" category without taking into account the reliable environment that 
provide the explicit support and set of safeguards set by the Governmental 
Authorities for such applications is a huge cause of concern.

For the aforementioned reasons, we request that: 

- the "uncalculated risk" label is retrieved from the .bcn application; 

- that this application is, if labeled at all, labeled as of "low risk"; 

- that the conclusions of this report cause no further delays of the roll-out 
plans prepared by the applicants;  

- and that those applications labeled as "uncalculated risk" are not prevented 
from starting the contracting process with ICANN.

puntCAT also wishes to express its support to the comments submitted  by 
CORE/AFNIC regarding Proposal to Mitigate Name Collision Risk, and has already 
expressed support to the NTAG Letter to the Board on Interisle Report through 
its position on the RySG supermajority support to such letter. 

Respectfully submitted

Nacho Amadoz
Legal Manager

Fundació puntCAT
http://domini.cat